- 2 -
Respondent determined a deficiency in petitioners’ Federal
income tax, an accuracy-related penalty, and an addition to tax
for 1997 as follows:
Penalty Addition to tax
Year Deficiency Sec. 6662 Sec. 6651(a)(1)
1997 $7,889 $1,577.80 $441
After concessions by petitioners,2 the issues for decision
are as follows:
(1) Whether for 1997, the taxable year in issue, petitioners
are entitled to a deduction under section 165(c)(2) for a loss
attributable to (a) the unauthorized removal of furnishings and
fixtures from an apartment building in 1996 and (b) the
foreclosure on such building in 1996. We hold that they are not.
(2) Whether petitioners are liable for the accuracy-related
penalty under section 6662(a) for negligence or intentional
disregard of rules or regulations. We hold that they are to the
extent provided herein.
2 In the petition, petitioners disputed the entire
deficiency determined by respondent in the notice of deficiency.
However, petitioners did not assign any error or allege any facts
with respect to respondent’s determinations regarding: (1) The
receipt of unreported nonemployee compensation in the amount of
$3,525; (2) the imposition of self-employment tax on such
nonemployee compensation; and (3) the disallowance of itemized
deductions for charitable contributions and unreimbursed employee
expenses. Moreover, at trial, petitioners did not dispute any of
these adjustments. Accordingly, we regard petitioners as having
conceded these matters.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011